NHTSA Interpretation File Search Overview Search Tool Request an Interpretation

NHTSA Interpretation File Search

Overview

NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.

Understanding NHTSA’s Online Interpretation Files

NHTSA makes its letters of interpretation available to the public on this webpage.

An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.

Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
Some combination of the above, or other, factors.

Searching NHTSA’s Online Interpretation Files

Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.

Single word search

Example: car
Result: Any document containing that word.

Multiple word search

Example: car seat requirements
Result: Any document containing any of these words.

Connector word search

Example: car AND seat AND requirements
Result: Any document containing all of these words.

Note: Search operators such as AND or OR must be in all capital letters.

Phrase in double quotes

Example: "headlamp function"
Result: Any document with that phrase.

Conjunctive search

Example: functionally AND minima
Result: Any document with both of those words.

Wildcard

Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).

Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).

Not

Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”

Complex searches

You can combine search operators to write more targeted searches.

Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).

Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”

Search Tool

NHTSA's Interpretation Files Search

Displaying 9501 - 9510 of 16490

Interpretations	Date

ID: aiam0924 Open Mr. Edward L. Hawes, Hawes Industries Inc., 1651 E. 9 Mile Road, Hazel Park, Michigan 48030; Mr. Edward L. Hawes Hawes Industries Inc. 1651 E. 9 Mile Road Hazel Park Michigan 48030; Dear Mr. Hawes: This is in response to your letter of October 30, 1972, regarding th amendment to Motor Vehicle Safety Standard No. 125, Warning Devices, published on June 22, 1972 (37 F.R. 12323). You observed that the preamble to that amendment erroneously described the device you manufacture as 'designed to be secured to the roof of a motor vehicle', while your device is actually secured to the window of the vehicle and displayed above the vehicle roof. Your request that the notice be amended to correct the description of the device.; As you have noted, the paragraph dealing with your device conclude that 'the standard does not prohibit manufacture or sale of a device capable of being mounted on a vehicle roof, so long as it meets all the Standard 125 requirements, including the capacity of being set up on the ground'. This language indicates that it is the clear intent of this agency to permit the manufacture and sale of a device such as you have described. Although I regret the misstatement concerning your device, I do not feel that a notice to clarify the preamble is called for.; Sincerely, Lawrence R. Schneider, Chief Counsel
ID: aiam3057 Open Don Strickland, Maryland Independent Automobile Dealers Association, 5210 West North Avenue, Baltimore, MD 21207; Don Strickland Maryland Independent Automobile Dealers Association 5210 West North Avenue Baltimore MD 21207; Dear Mr. Strickland: This to (sic) confirm your telephone conversation with Kathy DeMeter o my staff concerning the Federal Odometer disclosure requirements imposed on dealers and distributors. Part 580 of Title 49 of the Code of Federal Regulations requires that each transfer of a motor vehicle be accompanied by an odometer disclosure statement and that dealers and distributors retain for four years copies of statements which they issue and which they receive. In States that have incorporated the Federal statement into their certificates of title the dealer need not execute a separate Federal form. He must, nevertheless, retain a copy of whichever statement he completes. If, for example, he discloses the mileage solely by means of the statement on the certificate of title, he must make a copy of the title for his own records. He may also issue a separate statement to the purchaser and retain a copy of that statement for his records.; For your information, I have enclosed a copy of the law, th regulations issued under it and several interpretations and pamphlets. If you have any further questions, please do not hesitate to write.; Sincerely, John Womack, Assistant Chief Counsel
ID: aiam0376 Open Kenneth L. Harrigan, Esq., Messrs. Modrall, Seymour, Sperling, Roehl & Harris, Public Service Building, P.O. Box 2168, Albuquerque, New Mexico 87103; Kenneth L. Harrigan Esq. Messrs. Modrall Seymour Sperling Roehl & Harris Public Service Building P.O. Box 2168 Albuquerque New Mexico 87103; >>>Re: Gigler v. Volkswagen<<< Dear Mr. Harringan: In your letter of June 16 to Roman Brooks of this agency you ask fo background information on Federal Motor Vehicle Safety Standard No. 301, Fuel Tanks, Fuel Tank Filler Pipes, and Fuel Tank Connections, effective January 1, 1968.; Section 103(h) of the National Traffic and Motor Vehicle Safety Act o 1966 required that the initial safety standards be 'based upon existing safety standards.' Standard No. 301 was based upon General Services Agency Standard No. 515/26, Fuel Tanks and Tank Filler Pipes, effective October 13, 1967. As you know, the GSA standards were applicable only to vehicles purchased by the Federal Government. The two standards, however, are not identical, as an example, Standard No. 301 includes fuel tank connections, while GSA Standard No. 515/26 included a rear end collision test at 15 miles per hour. Perhaps GSA can provide you with background information on their standard if you deem it essential to your case.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel
ID: aiam3449 Open Ken Siemens, Metropolitan Property and Liability Insurance Company, Midwest Service Office, 9797 Springboro Pike, P.O. Box 48020, Dayton, OH 45448; Ken Siemens Metropolitan Property and Liability Insurance Company Midwest Service Office 9797 Springboro Pike P.O. Box 48020 Dayton OH 45448; Dear Mr. Siemens: This is in response to your letter of June 25, 1981, requesting listing of those states whose certificates of title have been approved by the agency for use in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odometer laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal form, the statemust obtain the approval of this agency before its certificate of title can be used as a substitute for the Federal form.; In order to spare states the burden of an apporval (sic) process th agency has indicated that certain variations from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1997, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl title forms that are consistent with the requirements of the Federal law:; >>>Maryland, Pennsylvania Massachusetts, Hawaii Michigan, New York Minnesota, North Dakota Ohio>>> In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each state was advised that before its form could be approved certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Virginia Delaware, Washington South Dakota, Utah South Carolina, Wisconsin Indiana If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, Assistant Chief Counsel
ID: aiam3420 Open Alden Lee, Gelco Fleet & Management Services Company, Three Gelco Drive, Eden Prairie, Minnesota 55344; Alden Lee Gelco Fleet & Management Services Company Three Gelco Drive Eden Prairie Minnesota 55344; Dear Mr. Lee: This is in response to your letter of April 13, 1981, requesting listing of those states whose certificates of title have been approved by the agency foruse in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odometer laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal form, the state must obtain the approval of this agency before its certificate of title can be used as a substitute for the Federal form.; In order to spare states the burden of an approval process the agenc has indicated that certain variations from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1977, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl title forms that are consistent with the requirements of the Federal law:; >>>Maryland, Pennsylvania Massachusetts, Hawaii Michigan, New York Minnesota, North Dakota Ohio>>> In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each state was advised that before its form could be approved certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Virginia Delaware, Washington South Dakota, Utah South Carolina, Wisconsin Indiana If you have any further questions, please do not hesitate to write. Sincerely, Shirley Ransom, Trial Attorney
ID: aiam3395 Open W.M. Bradley, Jr., Auto Damage Claim Examiner, Kemper Group, Mid-Atlantic Division, 1610 Forest Avenue, Richmond, VA 23288; W.M. Bradley Jr. Auto Damage Claim Examiner Kemper Group Mid-Atlantic Division 1610 Forest Avenue Richmond VA 23288; Dear Mr. Bradley: This is in response to your letter of February 10, 1978, requesting listing of those states whose certificates of title have been approved by the agency for use in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odmeter (sic) laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal from (sic), the state must obtain the approval of this agency before its certificate of title can be used as a sustitute for the Federal form.; In order to spare states the burden of an approval process the agenc has indicated that certain variation from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1977, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl titles that are consistent with the requirements of the federal law:; >>>Maryland, Ohio, Massachusetts, Pennsylvania, Michigan, Hawaii Minnesota, New York, North Dakota<<<; In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each was advised that before its form could be approved certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Virginia, Delaware, Washington, South Dakota, Utah South Carolina, Wisconsin, Indiana<<<; If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, assistant Chief Counsel
ID: aiam3514 Open William D. Brusstar, Jr., Esq., General Motors Corporation, General Motors Building, 3044 West Grand Boulevard, Detroit, MI 48207; William D. Brusstar Jr. Esq. General Motors Corporation General Motors Building 3044 West Grand Boulevard Detroit MI 48207; Dear Mr. Brusstar: This is in response to your letter of December 16, 1981, requesting listing of those states whose certificates of title have been approved by the agency for use in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odometer laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal form, the state must obtain the approval of this agency before its certificate of title can be used as a substitute for the Federal form.; In order to spare states the burden of an apporval (sic) process th agency has indicated that certain variations from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1977, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl title forms that are consistent with the requirements of the Federal law:; >>>Maryland, Massachusetts, Michigan, Minnesota, Ohio, Pennsylvania Hawaii, New York, North Dakota<<<; In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each state was advised that before its form could be approved, certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Delaware, South Dakota, South Carolina, Indiana Virginia, Washington, Utah, Wisconsin, New Mexico<<<; If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, Assistant Chief Counsel
ID: aiam4375 Open Mr. William Shapiro, Manager, Regulations and Compliance, Volvo Cars of North America, Rockleigh, NJ 07647; Mr. William Shapiro Manager Regulations and Compliance Volvo Cars of North America Rockleigh NJ 07647; Dear Mr. Shapiro: This responds to your letter concerning the Part 581 Bumper Standard You asked whether headlamp washer- wiper systems should be removed from a vehicle prior to testing. As discussed below, the answer to your question is yes.; By way of background information, the National Highway Traffic Safet Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the statutes administered by NHTSA, it is the responsibility of the manufacturer to ensure that its vehicles and equipment comply with applicable requirements.; Section 581.6 of the Bumper Standard specifies a number of condition which apply to the standard's impact tests. One of these conditions, set forth in paragraph (a)(5), is that '(t)railer hitches, license plate brackets, and headlamp washers are removed from the vehicle.' You stated that the standard was promulgated prior to the advent of headlamp washer-wiper systems, and suggested that the interpretation of 'headlamp washers' can be expanded to include headlamp washer-wiper systems. It is our opinion that for purposes of the Part 581 Bumper (sic) the term 'headlamp washers' is sufficiently broad to include headlamp washer-wiper systems.; Sincerely, Erika Z. Jones, Chief Counsel
ID: aiam1860 Open Honorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This responds to your recent communication requesting consideration o a constituent's concern about the National Highway Traffic Safety Administration's standard requiring antiskid devices on new school buses for all states, although some states do not often have icy roads.; The regulation to which your constituent Mr. Smith refers is Federa Motor Vehicle Safety Standard No. 121, Air brake systems. This standard which became effective for trailers on January 1, 1975, and trucks and buses on March 1, 1975, specifies minimum performance requirements for service brake systems, emergency brake systems, and parking brake systems utilized on air-braked vehicles. The standard does not specifically require antilock devices, although S5.3.1 of the standard does specify minimum stopping distance and stability requirements on dry and wet roads. Most vehicle manufacturers have decided to utilize antilock devices to meet these requirements. The purpose of these requirements is to enhance vehicle stability during brake application on roads in all conditions, dry and wet, as well as icy. A copy of Standard No. 121 with amendments is enclosed.; Please write again if I can be of further assistance. Sincerely, James C. Schultz, Chief Counsel
ID: aiam3773 Open Mr. Austin Basham, Director, Motor Vehicle Division, Transportation Department, Manuel Lujan Senior Building, Santa Fe, New Mexico 87503; Mr. Austin Basham Director Motor Vehicle Division Transportation Department Manuel Lujan Senior Building Santa Fe New Mexico 87503; Dear Mr. Basham: On April 9, 1982, the National Highway Traffic Safety Administratio (NHTSA) approved New Mexico's odometer disclosure statement for use in lieu of a separate Federal form.; Pursuant to a recent inquiry, I have found that New Mexico is no longe using this approved form. New Mexico's current Certificate of Title does not satisfy the requirements of 49 CFR Part 580 and, therefore, the Federal odometer disclosure statement must be used.; If New Mexico wants to use its Certificate of Title in lieu of separate Federal form, it must include a statement which refers to State or Federal law, and must include a space for the purchaser's signature. NHTSA considers this signature to be essential because it is an acknowledgment that the purchaser was aware of the mileage. The purchaser, when he signs the document, is prevented from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title. Additionally, Part 580.4(c) requires that three statements be included on the odometer disclosure statement. New Mexico's title certificate fails to include the first of these three. While it does provide a space for the odometer mileage, it fails to include a statement, as required by this section, stating that the transferor 'certif ies that to the best of his knowledge the odometer reading reflects the actual miles or kilometers the vehicle has been driven.'; It was suggested that New Mexico's Application for Vehicle Title an Registration may be used in lieu of a Federal odometer disclosure statement. This form, however, does not include all required information. The odometer disclosure statement must include the information specified in 49 CFR S 580.4(a)-(e). Alternatively, in accordance with 49 CFR S580.4(f), a 'State certificate of title or such other ownership document' may be used as a substitute and need only include information required by (a), (b), (c) and (e). An application for vehicle title and registration does not constitute an ownership document, and the application fails to include all information specified in Part 580.4(a)-(e).; Sincerely, Frank Berndt, Chief Counsel

Request an Interpretation

You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:

The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590

If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.

Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.

Interpretations	Date

ID: aiam0924 Open Mr. Edward L. Hawes, Hawes Industries Inc., 1651 E. 9 Mile Road, Hazel Park, Michigan 48030; Mr. Edward L. Hawes Hawes Industries Inc. 1651 E. 9 Mile Road Hazel Park Michigan 48030; Dear Mr. Hawes: This is in response to your letter of October 30, 1972, regarding th amendment to Motor Vehicle Safety Standard No. 125, Warning Devices, published on June 22, 1972 (37 F.R. 12323). You observed that the preamble to that amendment erroneously described the device you manufacture as 'designed to be secured to the roof of a motor vehicle', while your device is actually secured to the window of the vehicle and displayed above the vehicle roof. Your request that the notice be amended to correct the description of the device.; As you have noted, the paragraph dealing with your device conclude that 'the standard does not prohibit manufacture or sale of a device capable of being mounted on a vehicle roof, so long as it meets all the Standard 125 requirements, including the capacity of being set up on the ground'. This language indicates that it is the clear intent of this agency to permit the manufacture and sale of a device such as you have described. Although I regret the misstatement concerning your device, I do not feel that a notice to clarify the preamble is called for.; Sincerely, Lawrence R. Schneider, Chief Counsel
ID: aiam3057 Open Don Strickland, Maryland Independent Automobile Dealers Association, 5210 West North Avenue, Baltimore, MD 21207; Don Strickland Maryland Independent Automobile Dealers Association 5210 West North Avenue Baltimore MD 21207; Dear Mr. Strickland: This to (sic) confirm your telephone conversation with Kathy DeMeter o my staff concerning the Federal Odometer disclosure requirements imposed on dealers and distributors. Part 580 of Title 49 of the Code of Federal Regulations requires that each transfer of a motor vehicle be accompanied by an odometer disclosure statement and that dealers and distributors retain for four years copies of statements which they issue and which they receive. In States that have incorporated the Federal statement into their certificates of title the dealer need not execute a separate Federal form. He must, nevertheless, retain a copy of whichever statement he completes. If, for example, he discloses the mileage solely by means of the statement on the certificate of title, he must make a copy of the title for his own records. He may also issue a separate statement to the purchaser and retain a copy of that statement for his records.; For your information, I have enclosed a copy of the law, th regulations issued under it and several interpretations and pamphlets. If you have any further questions, please do not hesitate to write.; Sincerely, John Womack, Assistant Chief Counsel
ID: aiam0376 Open Kenneth L. Harrigan, Esq., Messrs. Modrall, Seymour, Sperling, Roehl & Harris, Public Service Building, P.O. Box 2168, Albuquerque, New Mexico 87103; Kenneth L. Harrigan Esq. Messrs. Modrall Seymour Sperling Roehl & Harris Public Service Building P.O. Box 2168 Albuquerque New Mexico 87103; >>>Re: Gigler v. Volkswagen<<< Dear Mr. Harringan: In your letter of June 16 to Roman Brooks of this agency you ask fo background information on Federal Motor Vehicle Safety Standard No. 301, Fuel Tanks, Fuel Tank Filler Pipes, and Fuel Tank Connections, effective January 1, 1968.; Section 103(h) of the National Traffic and Motor Vehicle Safety Act o 1966 required that the initial safety standards be 'based upon existing safety standards.' Standard No. 301 was based upon General Services Agency Standard No. 515/26, Fuel Tanks and Tank Filler Pipes, effective October 13, 1967. As you know, the GSA standards were applicable only to vehicles purchased by the Federal Government. The two standards, however, are not identical, as an example, Standard No. 301 includes fuel tank connections, while GSA Standard No. 515/26 included a rear end collision test at 15 miles per hour. Perhaps GSA can provide you with background information on their standard if you deem it essential to your case.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel
ID: aiam3449 Open Ken Siemens, Metropolitan Property and Liability Insurance Company, Midwest Service Office, 9797 Springboro Pike, P.O. Box 48020, Dayton, OH 45448; Ken Siemens Metropolitan Property and Liability Insurance Company Midwest Service Office 9797 Springboro Pike P.O. Box 48020 Dayton OH 45448; Dear Mr. Siemens: This is in response to your letter of June 25, 1981, requesting listing of those states whose certificates of title have been approved by the agency for use in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odometer laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal form, the statemust obtain the approval of this agency before its certificate of title can be used as a substitute for the Federal form.; In order to spare states the burden of an apporval (sic) process th agency has indicated that certain variations from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1997, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl title forms that are consistent with the requirements of the Federal law:; >>>Maryland, Pennsylvania Massachusetts, Hawaii Michigan, New York Minnesota, North Dakota Ohio>>> In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each state was advised that before its form could be approved certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Virginia Delaware, Washington South Dakota, Utah South Carolina, Wisconsin Indiana If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, Assistant Chief Counsel
ID: aiam3420 Open Alden Lee, Gelco Fleet & Management Services Company, Three Gelco Drive, Eden Prairie, Minnesota 55344; Alden Lee Gelco Fleet & Management Services Company Three Gelco Drive Eden Prairie Minnesota 55344; Dear Mr. Lee: This is in response to your letter of April 13, 1981, requesting listing of those states whose certificates of title have been approved by the agency foruse in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odometer laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal form, the state must obtain the approval of this agency before its certificate of title can be used as a substitute for the Federal form.; In order to spare states the burden of an approval process the agenc has indicated that certain variations from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1977, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl title forms that are consistent with the requirements of the Federal law:; >>>Maryland, Pennsylvania Massachusetts, Hawaii Michigan, New York Minnesota, North Dakota Ohio>>> In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each state was advised that before its form could be approved certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Virginia Delaware, Washington South Dakota, Utah South Carolina, Wisconsin Indiana If you have any further questions, please do not hesitate to write. Sincerely, Shirley Ransom, Trial Attorney
ID: aiam3395 Open W.M. Bradley, Jr., Auto Damage Claim Examiner, Kemper Group, Mid-Atlantic Division, 1610 Forest Avenue, Richmond, VA 23288; W.M. Bradley Jr. Auto Damage Claim Examiner Kemper Group Mid-Atlantic Division 1610 Forest Avenue Richmond VA 23288; Dear Mr. Bradley: This is in response to your letter of February 10, 1978, requesting listing of those states whose certificates of title have been approved by the agency for use in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odmeter (sic) laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal from (sic), the state must obtain the approval of this agency before its certificate of title can be used as a sustitute for the Federal form.; In order to spare states the burden of an approval process the agenc has indicated that certain variation from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1977, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl titles that are consistent with the requirements of the federal law:; >>>Maryland, Ohio, Massachusetts, Pennsylvania, Michigan, Hawaii Minnesota, New York, North Dakota<<<; In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each was advised that before its form could be approved certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Virginia, Delaware, Washington, South Dakota, Utah South Carolina, Wisconsin, Indiana<<<; If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, assistant Chief Counsel
ID: aiam3514 Open William D. Brusstar, Jr., Esq., General Motors Corporation, General Motors Building, 3044 West Grand Boulevard, Detroit, MI 48207; William D. Brusstar Jr. Esq. General Motors Corporation General Motors Building 3044 West Grand Boulevard Detroit MI 48207; Dear Mr. Brusstar: This is in response to your letter of December 16, 1981, requesting listing of those states whose certificates of title have been approved by the agency for use in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odometer laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal form, the state must obtain the approval of this agency before its certificate of title can be used as a substitute for the Federal form.; In order to spare states the burden of an apporval (sic) process th agency has indicated that certain variations from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1977, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl title forms that are consistent with the requirements of the Federal law:; >>>Maryland, Massachusetts, Michigan, Minnesota, Ohio, Pennsylvania Hawaii, New York, North Dakota<<<; In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each state was advised that before its form could be approved, certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Delaware, South Dakota, South Carolina, Indiana Virginia, Washington, Utah, Wisconsin, New Mexico<<<; If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, Assistant Chief Counsel
ID: aiam4375 Open Mr. William Shapiro, Manager, Regulations and Compliance, Volvo Cars of North America, Rockleigh, NJ 07647; Mr. William Shapiro Manager Regulations and Compliance Volvo Cars of North America Rockleigh NJ 07647; Dear Mr. Shapiro: This responds to your letter concerning the Part 581 Bumper Standard You asked whether headlamp washer- wiper systems should be removed from a vehicle prior to testing. As discussed below, the answer to your question is yes.; By way of background information, the National Highway Traffic Safet Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the statutes administered by NHTSA, it is the responsibility of the manufacturer to ensure that its vehicles and equipment comply with applicable requirements.; Section 581.6 of the Bumper Standard specifies a number of condition which apply to the standard's impact tests. One of these conditions, set forth in paragraph (a)(5), is that '(t)railer hitches, license plate brackets, and headlamp washers are removed from the vehicle.' You stated that the standard was promulgated prior to the advent of headlamp washer-wiper systems, and suggested that the interpretation of 'headlamp washers' can be expanded to include headlamp washer-wiper systems. It is our opinion that for purposes of the Part 581 Bumper (sic) the term 'headlamp washers' is sufficiently broad to include headlamp washer-wiper systems.; Sincerely, Erika Z. Jones, Chief Counsel
ID: aiam1860 Open Honorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This responds to your recent communication requesting consideration o a constituent's concern about the National Highway Traffic Safety Administration's standard requiring antiskid devices on new school buses for all states, although some states do not often have icy roads.; The regulation to which your constituent Mr. Smith refers is Federa Motor Vehicle Safety Standard No. 121, Air brake systems. This standard which became effective for trailers on January 1, 1975, and trucks and buses on March 1, 1975, specifies minimum performance requirements for service brake systems, emergency brake systems, and parking brake systems utilized on air-braked vehicles. The standard does not specifically require antilock devices, although S5.3.1 of the standard does specify minimum stopping distance and stability requirements on dry and wet roads. Most vehicle manufacturers have decided to utilize antilock devices to meet these requirements. The purpose of these requirements is to enhance vehicle stability during brake application on roads in all conditions, dry and wet, as well as icy. A copy of Standard No. 121 with amendments is enclosed.; Please write again if I can be of further assistance. Sincerely, James C. Schultz, Chief Counsel
ID: aiam3773 Open Mr. Austin Basham, Director, Motor Vehicle Division, Transportation Department, Manuel Lujan Senior Building, Santa Fe, New Mexico 87503; Mr. Austin Basham Director Motor Vehicle Division Transportation Department Manuel Lujan Senior Building Santa Fe New Mexico 87503; Dear Mr. Basham: On April 9, 1982, the National Highway Traffic Safety Administratio (NHTSA) approved New Mexico's odometer disclosure statement for use in lieu of a separate Federal form.; Pursuant to a recent inquiry, I have found that New Mexico is no longe using this approved form. New Mexico's current Certificate of Title does not satisfy the requirements of 49 CFR Part 580 and, therefore, the Federal odometer disclosure statement must be used.; If New Mexico wants to use its Certificate of Title in lieu of separate Federal form, it must include a statement which refers to State or Federal law, and must include a space for the purchaser's signature. NHTSA considers this signature to be essential because it is an acknowledgment that the purchaser was aware of the mileage. The purchaser, when he signs the document, is prevented from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title. Additionally, Part 580.4(c) requires that three statements be included on the odometer disclosure statement. New Mexico's title certificate fails to include the first of these three. While it does provide a space for the odometer mileage, it fails to include a statement, as required by this section, stating that the transferor 'certif ies that to the best of his knowledge the odometer reading reflects the actual miles or kilometers the vehicle has been driven.'; It was suggested that New Mexico's Application for Vehicle Title an Registration may be used in lieu of a Federal odometer disclosure statement. This form, however, does not include all required information. The odometer disclosure statement must include the information specified in 49 CFR S 580.4(a)-(e). Alternatively, in accordance with 49 CFR S580.4(f), a 'State certificate of title or such other ownership document' may be used as a substitute and need only include information required by (a), (b), (c) and (e). An application for vehicle title and registration does not constitute an ownership document, and the application fails to include all information specified in Part 580.4(a)-(e).; Sincerely, Frank Berndt, Chief Counsel

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